ML17291A208

Responds to NRC 940608 Ltr Re Violation Noted in Insp Rept 50-397/94-18.Corrective Actions:Walkdown Was Initiated Immediately to Determine If Any Other Untreated Wood Could Be Found in Plant

ML17291A208
Person / Time
Site:	Columbia
Issue date:	07/08/1994
From:	Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-94-157, NUDOCS 9407180158
Download: ML17291A208 (8)

Text

A LXL ~ LXx (ACCELERATED RIDS PROCESSING)

REGULATORY INFORMAT1ON DISTRIBUTION SYSTEM (RIDS)

CESSION NBR:9407180158 DOC.DATE: 94/07/08 NOTARIZED: NO DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION PARRISH,J.V. Washington Public Power Supply System P RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 940608 ltr re violations noted in insp rept 50-397/94-18.Corrective actions:walkdown was initiated immediately to determine found in plant if any untreated wood could be 0

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR 'NCL J SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation R sponse NOTES RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDIV-3 PD 1 1 CLIFFORD,J 1 1 INTERNAL: ACRS 2 2 AEOD/DEIB 1 1 AEOD/DS P/ROAB 1 1 AEOD/DSP/TPAB 1 1 AEOD/TTC 1 1 DEDRO 1 1 NRR/DORS/OEAB 1 1 NRR/DRCH/HHFB 1 1 NRR/PMAS/IRCB-E 1 1 NUDOCS-ABSTRACT 1 1 0 D 1 1 OGC/HDS3 1 1 G I.LE 02 1 1 RES/HFB 1 1" RG ILE 01 1 1 D

EXTERNAL: EG&G/BRYCE,J.H. ~ ~ 1 1 NRC PDR 1 1 NSIC 1 1 U

NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE iVASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2083 ) TO ELIMINATEYOUR NAME FROM DISTRIBUTIONLISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL 21

WASHINGTON PUBLIC POWER SUPPLY SYSTEM PO. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352-0968 ~ (509) 372-5000 July 8, 1994 G02-94-157 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station Pl-37 Washington, D. C. 20555 Gentlemen:

Subject:

WNP-2, OPERATING LICENSE NO. NPF-21 NRC INSPECTION REPORT 94-18 RESPONSE TO NOTICE OF VIOLATION The Washmgton Pubhc Power Supply System hereby rephes to the Notice of Violation contained in your letter dated June 8, 1994. Our reply, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of Appendix A (attached) which addresses the specifics of the Notice of Violation, and this letter which outlines Quality Assurance overview activities of the Inservice Inspection Program.

Prior to.the NRC Inspection, Quality Assurance had recognized that the ISI Program had not been subject to the level of comprehensive assessment efforts appropriate to this area. The Inspection Report accurately reflects our commitment to improve our oversight of this area through current and future assessments. Ongoing assessment activity primarily involves the Mechanical Stress Improvement Process (MSIP), a project conducted during R-9 to relieve stresses on reactor pressure vessel safe-end welds.

The MSIP was chosen for assessment due to its potential safety impact and to assure adequate contractor craft and oversight performance. The scope of the assessment included: adequacy of planning and preparation, observation of work in the field, effectiveness of training, independent verification of weld locations and weld treatments, verification of stress relief calculations, and adherence to radiation protection requirements. During the MSIP assessment, QA dedicated a total of 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> to observation of activities in the field. This included 40 pr,n<

kvv Vv ie 9407180158 940708 050003'P7 PDR ADOCY~

9 PDR

0

~Y Page 2 NRC INSPECTION REPORT 94-18 RESPONSE TO NOTICE OF VIOLATION hours of in-Drywell observation; including performing independent verification of the weld locations for six of the forty-four nozzles, observation of equipment set up, and the actual weld treatment of eight nozzles. The extent of these verification activities was chosen in an effort to balance ALARA considerations and the amount of observation necessary to assure work was being conducted properly. r Should you have any questions or'desire additional information regarding this matter, please call me or D. A. Swank at (509) 377-4563.

Sincerely,

. V. Parrish (Mail Drop 1023)

Assistant Managing Director, Operations CJF/bk Attachments CC: LJ Callan - NRC RIV KE Perkins, Jr. - NRC RIV, Walnut Creek Field Office NS Reynolds - Winston & Strawn JW Clifford - NRC DL Williams - BPA/399 NRC Sr. Resident Inspector - 927N

0 Appendix A VIOLATI N During an NRC inspection conducted on May 16 - 20, 1994, one violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:

Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented, and maintained covering the fire protection program implementation.

Administrative Procedure 1.3.10, "Fire Protection Program Implementation," Revision 15, requires that temporary wood/blocking used in the plant shall be treated with a listed pressure impregnated fire retardant process, ifpossible. As a minimum, it Underwriters'aboratory shall be treated with a painted on, flame retardant.

Contrary to the above, on May 18, 1994, the inspector observed wood stored on elevation 501 foot inside the reactor building. This wood was not treated or painted with a flame retardant.

R P NET VI LATI N The Supply System accepts this violation.

REASONF R THE VIOLATI N The root cause of the violation was failure to enforce existing procedural controls for use of wood in plant fire areas. The event occurred during the annual refueling outage.

Maintenance activities often include use of wood for bracing, use of wooden pallets for moving equipment and supplies, etc. The existing procedure requires that all wood to be brought into the plant be either impregnated with fire retardant or treated externally with a flame retardant, and be accompanied by a Transient Combustible Permit. Untreated wood may be used only after review by the Fire Marshal, issuance of a Transient Combustible Permit, and arrangement of continuous monitoring of the material until removed. However, more structured methods are needed to facilitate compliance with these procedural requirements.

RRE TIVE TEP TAKE R T A HIEVED

1. A walkdown was initiated immediately to determine if any other untreated wood could be found in the plant. Several pieces of untreated wood were found, and promptly removed from the buildings, or in some cases treated in-situ with fire retardant paint.

Appendix A Page 2 of 2

2. Labels were affixed to doorways and hatches in the Reactor, Turbine-Generator, Radwaste, Diesel-Generator, Circulating Water Pumphouse, and Standby Service Water Pumphouse Buildings to warn personnel that'untreated wood must not be brought into those plant areas, except as prescribed by procedure, PPM 1.3.10. The labels state: "Attention! No Untreated Wood Beyond This Point. (Refer to PPM 1.3.10 for requirements) Direct questions to the Plant Fire Marshal".

3. Training was conducted to emphasize to Supply System and Bechtel maintenance, project, health physics, and construction personnel that PPM 1.3. 10 requires that:

untreated wood generally not be used in the plant.

wood to be used on a temporary basis must either be impregnated with fire retardant or painted with an approved flame retardant, and exceptions, if any, must be specifically reviewed and approved by the Fire Marshal.

RRE TIVE TEP T BE TAKEN Plant procedure PPM 1.3.10 will be revised by September 15, 1994 to strengthen the policy that untreated wood shall not be permitted to be brought into the plant except under unusual circumstances.

ATE F F L MPLTA E The Supply System was in full compliance on June 6, 1994 when all untreated wood identified during the walkdown referred to above was either removed from the plant fire areas or treated in-situ with flame retardant paint.